Schaffer v. United States
United States Supreme Court
362 U.S. 511 (1960)
Seven people were indicted together for conspiring to transport stolen clothing across state lines, but after the three defendants connected to every shipment pled guilty or had charges dismissed, the trial court dismissed the conspiracy count for lack of evidence, leaving four remaining defendants (Schaffer and others) tied to separate, unrelated shipments to different states. The prosecution presented the evidence against each remaining defendant separately, and the judge specifically instructed the jury not to consider evidence against one defendant as proof against any other; the defendants sought acquittal but never moved for a new trial or severance after the conspiracy count was dismissed, and the jury convicted all four, with the appellate court finding no resulting prejudice.
Whether, under the Federal Rules of Criminal Procedure, defendants must show prejudice to obtain separate trials of properly joined charges.